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REPORT TO THE HUMAN RIGHTS AND EQUAL OPPORTUNITY
COMMISSION
TELSTRA CORPORATION’S DISABILITY ACTION PLAN 1996 - 1998
document.doc
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2 December 1999
Ms Susan HallidayActing Disability Discrimination CommissionerHuman Rights and Equal Opportunity CommissionPiccadilly TowerLevel 8, 133 Castlereagh StreetSYDNEY NSW 2000
Dear Ms Halliday,
It is with pleasure that I submit this Report on the implementation of Telstra’s first
Disability Action Plan 1996 - 1998. Telstra was proud to be the first major
Corporation to develop and lodge a Disability Action Plan with the Commission.
Over the past three years, the telecommunications industry has experienced
extensive and rapid growth. The industry has expanded from a duopoly to one with
multiple carriers and carriage service providers. There has been an explosion of
new products and services onto the market at the same time as a substantial
decrease in the costs to the public of basic telephone services. The way we do
business and conduct our daily lives has changed with the increase in the use of the
Internet, e-mail and other data services, and the increased mobility afforded by data
transfer over mobile telephony.
I am pleased to report that the vast majority of our commitments have been either
fully or partially implemented and the efforts of the many staff in Telstra who worked
to achieve this significant outcome are appreciated. There is still much to be done.
Telstra is currently finalising its new Disability Action Plan 1999 - 2001, which I look
forward to submitting to you in the near future. Through the new Disability Action
Plan, Telstra will continue to work towards improved accessibility to products and
services for our customers.
It is with regret that I acknowledge the death of the first Disability Discrimination
Commissioner, Ms Elizabeth Hastings in October 1998. Ms Hastings achieved
much in establishing the Disability Discrimination Unit and the many projects in
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which she was involved during her time as the Disability Discrimination
Commissioner. Ms Hastings demonstrated her willingness to work with
government, business, community organisations and individuals to achieve positive
outcomes for people with a disability in Australia.
I would like to acknowledge Ms Hastings for the guidance she provided to my staff
on a range of issues. Her efforts set the standard for a cooperative working
relationship between Telstra and the Commission, which remains in place today.
Yours sincerely
Graeme B Ward
Group Managing DirectorPublic Affairs and Corporate MarketingTelstra Corporation Ltd
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TABLE OF CONTENTS
Executive Summary
1. Introduction and Objectives of the Report
2. Changes to the Telecommunications Industry and its Regulation
Introduction of the Telecommunications Act 1997
Increased consultation with industry and consumer groups
3. Development and Evolution of Telstra’s Disability Action Plan
4. Governance and Monitoring of Telstra’s Disability Action Plan
5. Review of Telstra’s Disability Action Plan5.1 Process
5.1.1 PwC Review
5.1.2 Consumer Feedback
5.2 Results of the Nine StrategiesStrategy 1: Develop a Telstra Corporate Disability Policy and DDA
Compliance Program
Strategy 2: Develop a Disability Awareness Program for all staff
Strategy 3: Ensure ongoing consultation and consideration of
developments external to Telstra
Strategy 4: Improve accessibility to Telstra’s buildings and facilities
Strategy 5: Improve accessibility to information for people with a
disability
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Strategy 6: Improve accessibility to Telstra’s new products and
services
Strategy 7: Improve access to Telstra’s existing Products and
Services
Strategy 8: Maintain Telstra’s commitment to the elimination of
discrimination in the workplace in accordance with EEO
policy
Strategy 9: Incorporate DDA requirements into existing Telstra
policies and programs
5.2.1 Consumer Feedback
6. HREOC Complaints
7. Future Direction
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Executive Summary
Telstra was the first major corporate to develop and lodge a Disability Action
Plan with the Human Rights and Equal Opportunity Commission. Telstra
lodged its Action Plan with the Commission on 3 December 1996,
International Day of Disabled People.
The Disability Action Plan submitted in 1996 consisted of a mission statement
and nine strategies. These strategies were:
1. Develop a Telstra Corporate Disability Policy and DDA Compliance
Program.
2. Develop a Disability Awareness Program for all staff.
3. Ensure ongoing consultation and consideration of developments external
to Telstra.
4. Improve accessibility to Telstra’s buildings and facilities.
5. Improve accessibility to information for people with a disability.
6. Improve accessibility to Telstra’s new products and services.
7. Improve access to Telstra’s existing Products and Services.
8. Maintain Telstra’s commitment to the elimination of discrimination in the
workplace in accordance with EEO policy.
9. Incorporate DDA requirements into existing Telstra policies and programs.
The objective of this Report is to provide the Human Rights and Equal
Opportunity Commission (HREOC) with the status of the implementation of
Telstra’s Disability Action Plan.
There have been many changes to the telecommunications industry since
Telstra first submitted its Disability Action Plan in 1996. These include:
Opening of the telecommunications industry to full competition;
Changes to legislation (including the expansion of the Universal Service
Obligation);
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Promotion of industry self regulation as a key plank of the
telecommunications regime;
Increased number of products and services;
Decrease in prices for long distance calls;
Increased consumer consultation;
Increased consumer expectations; and
Increased community awareness of the DDA.
While the format of Telstra’s consultation with representatives of disability
consumer organisations has changed, Telstra has continued to consult widely
with consumer and industry groups.
Telstra is proud of its commitment to people with disabilities whether they be
customers or employees. Telstra remains committed to increasing the
number of employees with disabilities.
As detailed in the Disability Action Plan, Telstra planned to perform a review
of the initiatives included in the Disability Action Plan and prepare a report to
the Human Rights and Equal Opportunity Commission regarding the status of
the implementation of the nine strategies outlined in the Plan.
PricewaterhouseCoopers (“PwC”) was appointed to perform this review. PwC
reviewed the status of each action point detailed in the Disability Action Plan.
The results of the PricewaterhouseCoopers work were based on discussions
held with Telstra employees along with sighting of primary evidence to
indicate action against each item in the Disability Action Plan. The PwC
report is dated 4 February 1999.
The findings for each strategy as at 4 February 1999 are summarised in the
table below. The table indicates the number of action points completed, in
progress or yet to be actioned for each strategy. It should be noted that for
items requiring ongoing action, if the action has been performed to date, the
action has been marked as completed.
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Strategy Complete In Progress
Not actioned
Total
1. Develop a Telstra Corporate Disability Policy and DDA Compliance Program.
1 1 0 2
2. Develop a Disability Awareness Program for all staff
1 4 1 6
3. Ensure ongoing consultation and consideration of developments external to Telstra
4 0 0 4
4. Improve accessibility to Telstra’s buildings and facilities
5 4 1 10
5. Improve accessibility to information for people with a disability
12 4 2 18
6. Improve accessibility to Telstra’s new products and services
3 0 1 4
7. Improve access to Telstra’s existing Products and Services, including:
Customer Premises Equipment (CPE) Payphone Services Operator Assisted Services Directory Services Mobile Communication Services Other products and services
Total
531331
16
1411
7
2
2
672433
25
8. Maintain Telstra’s commitment to the elimination of discrimination in the workplace in accordance with EEO policy
4 0 0 4
9. Incorporate DDA requirements into existing Telstra policies and programs
3 0 0 3
Total 49 20 7 76Total % 65% 26% 9% 100%
PricewaterhouseCoopers did not undertake a review of the effectiveness of
the Disability Action Plan. Consumer feedback was sought to gain a
qualitative perspective on the effectiveness of Telstra’s Disability Action Plan.
A Questionnaire was sent to members of Telstra’s Disability Consumer
Forum in March 1999 seeking their feedback on their perceptions of Telstra’s
progress against the Disability Action Plan (see section 5.2.1). Not all
consumers chose to provide feedback, and feedback was not received for all
items. Consumers were most satisfied with Telstra’s consumer consultation
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and the research projects either funded or initiated by Telstra. Of most
concern to consumers was the lack of direct access to Emergency 000 for
TTY users.
Telstra was notified by the Human Rights and Equal Opportunity Commission
of five Human Rights and Equal Opportunity Commission complaints during
the period 1996 – 1998. Two of the complaints have been resolved, one has
become the subject of a public inquiry and two, which were joined, are still
being conciliated.
Telstra is constantly striving to improve its products and services. We are
currently in the process of preparing our next three-year Disability Action Plan
and this will incorporate the key areas of:
improved accessibility to new and existing products and services,
information, and buildings and facilities,
regular complaints analysis,
improved staff awareness,
internal governance/compliance process,
ongoing community consultation, and
ongoing EEO strategies.
The next Disability Action Plan will also incorporate some of the items not
actioned from the first plan.
As detailed in our first plan, consideration is now being given as how best to
mainstream the Disability Action Plan initiatives into the normal business
planning and ongoing monitoring process of all business units. This will
ensure the initiatives are addressed on a regular basis by the business units
thus improving the products and services offered to people with disabilities.
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1. Introduction and Objective of the Report
The Disability Discrimination Act 1992 (“DDA”) came into effect in March
1993, making it unlawful to discriminate against people on the basis that they
have, or may have, a disability. The DDA makes provision in section 60 for a
service provider, such as Telstra, to prepare and implement an Action Plan,
which may be lodged with the Human Rights and Equal Opportunity
Commission (“HREOC”). Section 61 states that the Action Plan must include
provisions relating to:
the devising of policies and programs to achieve the objects of the DDA;
the communication of these policies and programs to staff;
the review of practices within the company with a view to identifying any
discriminatory practices;
the setting of goals and targets against which the success of the plan in
achieving the objects of the DDA may be assessed;
the means of evaluating the policies and programs; and
the appointment of staff to implement the above provisions.
Telstra was the first major Corporation to develop a Disability Action Plan and
lodge it with HREOC, which it did on 3 December 1996, International Day of
Disabled People.
Telstra’s first Disability Action Plan consisted of a mission statement and nine
strategies. These strategies were:
1. Develop a Telstra Corporate Disability Policy and DDA Compliance
Program.
2. Develop a Disability Awareness Program for all staff.
3. Ensure ongoing consultation and consideration of developments external
to Telstra.
4. Improve accessibility to Telstra’s buildings and facilities.
5. Improve accessibility to information for people with a disability.
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6. Improve accessibility to Telstra’s new products and services.
7. Improve access to Telstra’s existing Products and Services.
8. Maintain Telstra’s commitment to the elimination of discrimination in the
workplace in accordance with EEO policy.
9. Incorporate DDA requirements into existing Telstra policies and programs.
This report summarises the progress Telstra has made in relation to the nine
strategies detailed in the Disability Action Plan. The report consists of seven
sections:
Section 1: contains the introduction and objective of the report
Section 2: outlines changes to the telecommunication industry and its
regulation
Section 3: outlines the development and evolution of Telstra’s Disability
Action Plan
Section 4: outlines the governance and monitoring of the Disability Action
Plan
Section 5: details the status of the nine strategies outlined in the Disability
Action Plan including the PricewaterhouseCoopers (PwC) review and
consumer feedback
Section 6: outlines the complaints lodged against Telstra in the Human
Rights and Equal Opportunity Commission
Section 7: provides our conclusion and future direction for Telstra’s next
three year Disability Action Plan.
This report demonstrates Telstra’s commitment to people with disabilities,
both in terms of its internal policies and processes and external product and
service development. Telstra aims to build on the success of the first three-
year plan and continue to improve its service to people with disabilities.
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2. Changes in the Telecommunications Industry and its Regulation
Over the past three years, the telecommunications industry has undergone
extensive and rapid change. Full and open competition came into effect on
July 1, 1997 with the introduction of the Telecommunications Act 1997.
There has been an increase in the number of telecommunications carriers to
25 at the end of 1998, and many more carriage service providers.
In addition we have seen the introduction of many new products and services,
most notably a huge increase in Internet and data services and mobile
phones. This has had the effect of providing customers with a greater choice
of services, and providing opportunities for access that previously did not
exist.
The pricing of long distance calls has decreased significantly with a range of
special offers available from the various carriers and carriage service
providers.
The Telecommunications Act 1997The most significant change to legislation impacting on people with a
disability over the past three years was the expansion of the Universal
Service Obligation (“USO”) in 1997 to include the supply of customer
equipment upon request to enable people with a disability to access the
standard telephone service.
Telstra is required to supply equipment to people with a disability to meet its
obligations under the Disability Discrimination Act 1992 (“the DDA”) and the
Universal Service Obligation (“USO”) in the Telecommunications Act 1997.
The USO is now contained in the Telecommunications (Consumer Protection
and Service Standards) Act 1999. As the nominated national Universal
Service Provider, Telstra is obliged to ensure that standard telephone
services, payphones and prescribed carriage services (of which there are
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currently none) are reasonably accessible to all Australians, wherever they
reside or carry on business. For the purposes of the USO, the supply of the
standard telephone service includes the supply of customer equipment
(including equivalent disability equipment) upon request. The
telecommunications legislation provides a process for telecommunications
carriers to share the cost of funding the USO, although it should be noted that
this does not currently include the costs to Telstra of providing disability
equipment.
As the national Universal Service Provider, Telstra will, at the request of a
person with a disability and in conjunction with the provision of the standard
telephone service, supply disability equipment by way of hire to enable a
person with a disability to access the service at an equivalent rental cost.
The Telecommunications (Equipment for the Disabled) Regulations 1998
("the Regulations") which came into force on 25 June 1998 specify the kind of
customer equipment that is to be supplied to a person with a disability for use
in connection with the standard telephone service. The Regulations specify
the kind of customer equipment by way of functionality and include, by way of
example, the following products: TTY, modem, telebraille, the Touchfone 400,
the Touchfone 400 volume control, the Touchfone 200 voice aid, the Access
35 handsfree telephone or the Touchfone 200 Executive, an extension ringer
or general purpose alarm, a visual signal alert, a double adaptor, a
Holdaphone, and a cochlear implant telephone adapting device (TLP-102T or
TRP - 100T).
Telstra supplies these products under the Telstra Disability Equipment
Program (except for the telebraille which is no longer being manufactured and
the cochlear implant telephone adapting device which was launched on 21
September, 1999.
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The range of disability equipment provided under Telstra’s Disability
Equipment Program has varied over time. In September 1998, Telstra’s
Disability Equipment Program was expanded to provide customer equipment
that was formerly provided under the Telstra TTY Program and the Federal
Government’s National Relay Service - Telecommunications Equipment
Access ("NRS-TEA") Program. Under these two programs, people who are
deaf, have a speech or communication impairment or who are deaf and blind
were provided with a voucher towards the purchase of a teletypewriter
("TTY"), modem or telebraille. Government funding for the NRS-TEA program
ceased on 30 June 1998.
It should be noted that the provision of equipment through the Disability
Equipment Program does not preclude a customer from obtaining long
distance services from another carrier or carriage service provider.
Telstra’s Universal Service Plan, approved by the Minister for
Communications, Information Technology and the Arts in May 1998, sets out
information about the supply of the standard telephone service to people with
disabilities. This information as currently drafted, refers to the Telstra TTY
Program and the Telstra Disability Equipment Program. Telstra submitted a
revised draft of the disability section of its Universal Service Plan to the
Australian Communications Authority (“ACA”) as part of the ACA’s review of
the Plan. The revision was required because of the closure of the NRS-TEA
Program and the expansion of the Telstra Disability Equipment Program, in
keeping with the changed arrangements under the Universal Service regime.
The Telecommunications Act 1997 (and now the Telecommunications
(Consumer Protection and Service Standards) Act 1999) provides for a
National Relay Service to provide people who are deaf, or have a hearing
and/or speech impairment, with access to a standard telephone service on
terms and in circumstances that are comparable to those on which other
Australians have access to a standard telephone service. The National Relay
service is not part of the USO, although like the USO regime, the legislation
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requires telecommunications carriers to contribute to the cost of providing the
NRS. The National Relay Service operates 24 hours, 365 days per year and
is provided under contract to the Commonwealth Government by Australian
Communication Exchange Ltd.
In a further change under the Telecommunications Act 1997, the Australian
Communications Authority (ACA) can make a technical standard for customer
equipment that is used in connection with the standard telephone service
which is not designed for use by people with disabilities (ie. an ordinary
telephone) that would, via the inclusion of mandatory features, give persons
with a disability, greater access to this equipment. The ACIF has drafted a
disability standard (on behalf of the ACA). Telstra is working closely with ACIF
to develop the standard.
Increased consultation with industry and consumer groups
Australian Communications Industry Forum (ACIF)The passage of the Telecommunications Act 1997 gave rise, from 1 July
1997, to major changes to the regulation of the Australian
telecommunications industry, including the transfer of responsibility for
significant standardisation activities from the regulator to the industry . Whilst
there are still legislative requirements, obligations and safeguard provisions
with which industry participants must comply, it was intended that industry
itself initiate and drive regulation to the greatest extent possible.
In 1997, members of the telecommunications industry established the
Australian Communications Industry Forum (“ACIF”) as the industry body with
the responsibility of developing industry codes under the Telecommunications
Act 1997. ACIF also has a role in developing technical standards to be
adopted by the ACA which relate to customer equipment and customer
cabling, the interconnection of facilities and disability standards.
Industry provides ACIF with the experts to develop technical standards and
industry codes.
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On 25 February 1999, after consultation with disability sector associations,
ACIF established a Disability Advisory Body (DAB) to provide focussed
interaction with, including, as relevant, representation in the technical
standards and industry codes development process, of persons with
disabilities. Membership of the DAB comprises representatives of
associations covering persons with disabilities including vision, hearing,
speech, physical, and intellectual disabilities.
The DAB responsibility covers:
examination of proposals for the development of industry codes and
technical standards that have intrinsic disability implications;
examination of drafts, including public comment drafts, of industry codes
and technical standards for implications for persons with disabilities, and in
both cases, providing appropriate advice within the ACIF Executive and the
industry codes and technical standards development structure; and
facilitating the availability of representatives to advise, or participate in
Working Committees.
In essence, persons with disabilities have been given special exposure to the
work of, and representation within, the Standards and Codes development
process in ACIF.
In its relative short history, the DAB has shown it can contribute significantly
to identifying the need, in Consumer Codes, for adequate access facilities /
processes to service providers including special inquiry lines or operators,
TTY access, provision of information in alternative formats, and how a
complaint may be lodged.
(Telstra would like to acknowledge Mr Rex Christensen of the ACIF for
compiling this section of the Report for Telstra.)
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Funding of Consumer Representation There is provision in section 593 of the Telecommunications Act 1997, for the
Commonwealth to fund consumer representation and research in relation to
telecommunications. The funding is provided for consumer representation
by a range of consumer organisations, including organisations that represent
people with a disability.
ConclusionConsumers have expressed concern that in a telecommunications industry
that is open to full competition, there may be fewer protections available to
them and that their needs will not be addressed. Legislation such as the
Telecommunications Act 1997 and Disability Discrimination Act 1992 coupled
with industry self-regulation and increased consumer consultation will ensure
that consumers needs will continue to be accommodated. Competition has
undoubtedly resulted in greater choice of product and service offerings and
lower prices for basic services for all Australians, including people with a
disability.
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3. Development and Evolution of Telstra’s Disability Action Plan
The Disability Discrimination Act 1992 allows for an organisation to develop
and lodge a Disability Action Plan with the Human Rights and Equal
Opportunity Commission. The decision by Telstra came about as a result of
the process of resolving the Scott & Ors v Telstra case. This helped Telstra
to gain a better understanding of the workings of the Disability Discrimination
Act 1992 and its implications for Telstra.
Telstra conducted an initial review with the aim of gaining an understanding of
what process would need to be followed to develop a Disability Action Plan,
what issues would need to be addressed within an Action Plan, how an Action
Plan should be structured and from what sources input would need to be
obtained. As outlined in section 4 of the Disability Action Plan, the aims of the
review were also to:
identify priorities;
estimate the costs to the Corporation of DDA compliance;
establish a platform from which meaningful discussions with consumer
representatives could be achieved; and
establish benchmarks for what constitutes reasonable compliance.
Prior to the review, Telstra had an informal internal working group
comprised of representatives of key areas of the organisation that were
dealing with disability issues and were already engaged in active
consumer consultation. This group formed the basis of the DDA
Compliance Working Group. This group advised the Disability Services
Unit as to which policies, products and services were a priority for action,
and assisted the Disability Services Unit to conduct the internal part of the
review.
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At the same time, consumer representatives on Telstra’s Disability
Services Consumer Committee (DSCC) were invited to attend a workshop
to scope out what areas of the business, or issues Telstra needed to
address in its Disability Action Plan. A follow up forum was convened to
agree priorities with consumers – ie what commitments should be short,
medium and long term in the Plan.
Telstra also sought specialist advice from experts in the disability
discrimination field on a range of aspects of the process of development of
the Action Plan, and the content of the Plan itself. Information was
collated and a draft developed. Consultants were engaged to conduct
audits of Telstra payphones and buildings, in particular. A draft of the
Plan was circulated internally and externally to consumers and key
advisers, for comment. The final version of the Plan was launched at an
event on International Day of People with Disabilities, 3 December 1996,
attended by Ms Elizabeth Hastings, senior Telstra managers and
consumer representatives. Telstra officially lodged its Disability Action
Plan with the Human Rights and Equal Opportunity Commission on that
day.
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4. Governance and Monitoring of the Disability Action Plan
The development and ongoing monitoring of the Disability Action Plan was
overseen by Telstra’s Disability Services Unit.
A two-tiered governance process was established to monitor the Disability
Action Plan. This involved a Senior Management Compliance Group, chaired
by Graeme Ward (then Group Director, Regulatory & External Affairs) which
was to meet every six months. Representatives on the Senior Management
Compliance group were appointed by each of the Business Unit heads. Their
role is to provide strategic direction and advice about key aspects of Telstra’s
compliance with the Disability Discrimination Act.
The Senior Management Compliance Group was supported by a DDA
Compliance Working Group comprised of representatives from each of the
Business Units and key business areas within Telstra. The DDA Compliance
Working Group meetings were chaired by the National Manager, Consumer
Relations, and were to meet quarterly. With the majority of DDA impacts
being on Telstra’s products and services for Consumer customers (being
residential and small business customers), representation from a number of
business areas within Telstra’s Commercial and Consumer Business Unit
was required. The group provided regular reports on the progress of their
action points in the Plan. The group also provided practical guidance and
advice to Telstra management on what were the priority areas requiring
action.
Regular contact was maintained between business units, industry and
consumer groups. Telstra relied on research, consumer consultation (as
described under section 5, strategy 3) and the Disability Services Unit to
ensure the initiatives contained in the Disability Action Plan were achieved
where possible.
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Ongoing consultation and the move to more sector specific discussions on
new product developments or key areas of concern, has assisted Telstra to
achieve the best outcomes possible for people with disabilities.
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5. Review of Telstra’s Disability Action Plan
Telstra’s first Disability Action Plan covered the three-year period from 1996
to 1998. When the Plan was launched on December 3, 1996, work was well
under way to implement many of the actions outlined in the Plan.
Telstra indicated in Section 9 of the Plan that it would conduct a formal,
comprehensive review of its Disability Action Plan two years after its launch.
That review commenced in December 1998 and forms the basis of this
report.
5.1 Process
The review of Telstra’s first Disability Action Plan has been a three-stage
process. PricewaterhouseCoopers (“PwC”) was engaged to conduct an
independent review of Telstra’s Plan which included a testing methodology.
Further, consumer feedback was sought through disability representatives on
Telstra’s Disability Consumer Forum.
5.1.1 PwC Review
On engagement by Telstra, PwC’s first task was to develop a Testing Plan, by
which the status of each of the actions outlined in the Disability Action Plan
could be independently evaluated. While Appendix One of Telstra’s Disability
Action Plan identifies a range of Key Deliverables and Milestones, and
Appendix Two, Key Performance Measurements, it was agreed that the basis
on which Telstra reports its success in implementing the Plan, should be the
status of the individual actions outlined in each of the nine strategies.
The Testing Plan developed by PwC formed the structure for the review. The
results of the PricewaterhouseCoopers work were based on discussions held
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with Telstra employees along with the sighting of primary evidence to indicate
action against each item in the Disability Action Plan.
If an action has been fully implemented it is shown as ‘Complete’. Where an
action has been commenced but not fully implemented, it is shown as ‘In Progress’, and where implementation of an action has not commenced
(irrespective of the reason), it is shown as ‘Not Actioned’.
It should be noted that for items requiring ongoing action, if the action has
been performed to date, the action has been marked as ‘Complete’.
The findings for each strategy are summarised in the table in the Results
section in 5.2 below.
PricewaterhouseCoopers review was a quantitative review only, and did not
attempt to evaluate the effectiveness of the actions taken by Telstra to
implement its Disability Action Plan strategies.
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5.1.2 Consumer Feedback
Nine organisations represented on Telstra’s Disability Consumer Forum were
invited to complete a questionnaire which identified those actions where the
organisations could be expected to have knowledge of the actions taken by
Telstra to implement that strategy. Some items they would not have
knowledge of because they related to internal policies or processes. They
were asked to rate Telstra’s performance on qualitative grounds as ‘Satisfied’,
‘Partly Satisfied’, or ‘Not Satisfied’.
In all 19 actions under four key strategies were identified as appropriate for
consumer feedback:
Strategy 3: Ensure ongoing community consultation
Strategy 4: Improve accessibility to buildings and facilities
Strategy 5: Improve accessibility to information
Strategy 7: Improve accessibility to existing products and services,
including CPE, Payphones, OAS, Directory Services, Mobiles, and
other products and services
Not all organisations that were invited to provide feedback did so, and
feedback was not received on each action. Feedback is summarised in
section 5.2.1.
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5.2 Results of the Nine Strategies
This section reports on implementation of the nine strategies. The report
outlines the aims of the strategy, the PwC audit findings in percentage terms
and then a discussion of the actions taken by Telstra to implement the actions
under each strategy. The results of the PwC independent review as at 4
February 1999 are detailed in the following table:
Strategy Complete In Progress Not actioned Total1. Develop a Telstra Corporate Disability Policy and DDA Compliance Program.
1 1 0 2
2. Develop a Disability Awareness Program for all staff
1 4 1 6
3. Ensure ongoing consultation and consideration of developments external to Telstra
4 0 0 4
4. Improve accessibility to Telstra’s buildings and facilities
5 4 1 10
5. Improve accessibility to information for people with a disability
12 4 2 18
6. Improve accessibility to Telstra’s new products and services
3 0 1 4
7. Improve access to Telstra’s existing Products and Services, including:
Customer Premises Equipment (CPE) Payphone Services Operator Assisted Services Directory Services Mobile Communication Services Other products and services
Total
531331
16
1411
7
2
2
672433
25
8. Maintain Telstra’s commitment to the elimination of discrimination in the workplace in accordance with EEO policy
4 0 0 4
9. Incorporate DDA requirements into existing Telstra policies and programs
3 0 0 3
Total 49 20 7 76Total % 65% 26% 9% 100%
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Strategy 1: Develop a Telstra Corporate Disability Policy and DDA Compliance Program.
The aims of this strategy were to obtain senior level understanding and
endorsement of Telstra’s DDA compliance program and to provide a
framework for DDA compliance throughout the Corporation.
PricewaterhouseCoopers review found that 100% of actions had been either completed or were in progress for this strategy.
1.1 Endorsement of Corporate Disability Policy for inclusion in Telstra’s
Corporate Policy Manual.
Prior to the development of Telstra’s Disability Action Plan, a Corporate
Disability Policy was drafted. The Corporate Disability Policy was designed to
increase senior level understanding and endorsement of Telstra’s DDA
Compliance Program and set the broad policy direction that Telstra
management wanted the company to follow. In essence it states that people
with a disability have the same rights as the rest of the community and to the
best of its ability Telstra will aim to make its products and services accessible
to all its customers.
Initially, the Corporate Policy was provided in hard copy as part of Telstra’s
Corporate Policy manual, which had a limited distribution within the company
to managers and made available to their staff. More recently it, along with all
company policies, is now located on Telstra’s internal Intranet site and is
accessible to all staff either directly or through their supervisor.
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The Corporate Disability Policy was formally accepted and signed by Mr
Graeme Ward, Group Director, Regulatory and External Affairs, and Telstra
Chief Executive Officer, Mr Frank Blount on 28 November 1996.
1.2 Develop a Disability Compliance Manual to support the Disability Policy.
The intention in developing this strategy was that all relevant management
and staff (particularly those in customer facing areas) would have a written
reference manual which provided a framework for DDA compliance
throughout the corporation.
It was Telstra’s intention that the compliance manual include the disability
CPE product policies (Telstra TTY Program and the Disability Tariff
Concession Policy (now called the Disability Equipment Program), guidelines
for product and policy development, information and promotional material on
Telstra’s specialised products and services for people with disabilities, an
outline of management and staff compliance responsibilities, and the
inclusion of DDA compliance in relevant staff materials.
Since drafting the Disability Action Plan, new methods for storing and
disseminating information have been introduced throughout the company,
primarily the use of Intranet.
A comprehensive Corporate Disability Manual as such has not been
developed. There are a range of materials that have been made available to
target groups where a clear need has been identified, some of which are
outlined below (also see Strategy 2, action 2.1). In addition, a range of
materials is currently being developed which will be available to staff on
Telstra’s Intranet site.
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Materials that have been developed and which would have comprised the
Disability Compliance manual include the following:
The Disability Equipment Program (DEP) Policy is available to those staff
who directly administers the DEP Program. No formal policy document
was developed for the Telstra TTY Program, which now forms part of the
DEP.
Guidelines for product development were developed as part of the
Product Development Process documentation which includes the
Disability Impact Statement. These have been made available
electronically to all Product Managers and forms the foundations of some
of the mandatory stages of the current Product Development Operating
Model (see Strategy 6, action 6.1). The completion of the Disability
Impact Statement is mandatory for all new product developments.
Guidelines for the development of information and promotional materials
were obtained from Australian Association of the Deaf and National
Federation of Blind Citizens of Australia (now called Blind Citizens
Australia) and disseminated to management in Telstra’s Marketing
Communications Group. Additional guidelines have been obtained from
Villamanta Publishing.
Outline of management and staff compliance responsibilities - these have
been made available to members of both the Senior Management
Compliance Group and the DDA Compliance Working Group, and are
broadly outlined in Telstra’s Disability Policy.
DDA compliance guidelines have been included in a range of staff
manuals, such as training manuals and Help files.
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Comprehensive DDA related information has been provided via Infofax,
which is accessible to managers and staff across all Business Units.
Information provided via Infofax was promoted regularly via Telstra’s
Corporate publications.
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Strategy 2: Develop a Disability Awareness Program for all staff
This strategy was intended to ensure that information would be provided to all
Telstra management and staff to assist in the improvement of staff awareness
of the DDA and issues affecting people with a disability.
PricewaterhouseCoopers review found that 83% of actions had been completed or were in progress for this strategy.
2.1 Develop and implement a comprehensive disability awareness program
for all staff.
A working party was established to scope out what the requirements of a
Corporate wide Awareness Program would entail. A recommendation was
made that a 4-tiered program be implemented.
Tier 1: Top executive management with a “need to know” about Telstra’s
legal and regulatory obligations in relation to people with a disability.
Tier 2: Executive management who would have management responsibility
for disability related issues within their portfolios.
Tier 3: Managers and supervisors who would be directly supervising staff in
customer interface areas or developing products and services that directly or
indirectly impact on customers with a disability.
Tier 4: Customer facing staff who have a direct interface either in person or
by telephone with customers, including customers with a disability.
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Customer interfacing areas were seen as a top priority. Therefore, as a
starting point, a comprehensive 2-hour Disability Awareness Program was
developed which consisted of a training pack and a 9-minute video. There
were three versions of the last section of the training program, which
comprised approximately half of the total program, developed, to convey
information relevant to:
customer facing staff;
telephone sales and enquiry staff; and
field service staff;
and which contained specific information designed to improve communication
with people with a disability.
The video produced provides an overview of the nature and extent of
Telstra’s obligations in relation to our customers with a disability. In addition,
a targeted 30-minute Self-Paced Program was specifically developed for all
Operator Assisted Services (OAS) staff. The Self-Paced Workbook was
revised in late 1998, and updated to incorporate additional information about
newly developed operator assisted services, including the Directory
Assistance Disability Helpline.
The Disability Services Awareness training was updated in November 1997,
when Telstra’s Disability Enquiry Hotline was centralised. This was done in
conjunction with the update of Telstra’s Disability Equipment Program
training.
As previously mentioned, prior to the extensive use of the Intranet,
comprehensive information regarding the DDA has been provided via Infofax.
This information was accessible to all managers and staff and was promoted
regularly via Telstra’s Corporate publications.
While the PwC audit found that all existing training modules had not been
updated and therefore showed this item as “Not Actioned”, where possible
DDA principles and responsibilities have been incorporated into all relevant
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existing training modules, and been included in Induction and EEO training
programs. A Disability Awareness component was included in the Business
Imperatives course targeted at all managers and supervisors in Tier 3, in the
Executive Perspectives course targeted at Tier 2 managers. In addition,
similar information was provided to Tier 1 managers through periodic
Executive Memoranda from Graeme Ward, Group Director, Regulatory and
External Affairs.
Telstra’s Disability Policy is available on the Telstra Intranet site along with
Telstra’s policies.
Information has been distributed via the broad range of staff communications
media including Telstra’s flagship in-house weekly magazine Our Future,
which is distributed to all Telstra staff nationally and overseas.
2.2 Implement a series of information workshops and presentations for
Telstra management, product managers and product developers.
DDA compliance and awareness workshops have been conducted for key
areas of the business such as product managers and product developers. In
addition, the Disability Services Unit has had ongoing discussions with
product managers and developers through the Product Development
process.
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Strategy 3: Ensure ongoing Consultation and Consideration of Developments External to Telstra
This strategy focused on Telstra continuing to gather information from a
range of sources external to Telstra and ensure ongoing consultation with
representatives of the disability community.
PricewaterhouseCoopers review found that all actions had been completed for this strategy.
3.1 Continue ongoing community consultation on issues affecting people with
a disability.
The Disability Services Consultative Committee (DSCC) met 3 times during
1996 and 5 times during 1997. A broad range of issues was discussed,
including strategic regulatory and industry matters and Telstra product and
service developments. It was recognised at the end of 1997 that Telstra’s
consultation program needed to be reviewed and the DSCC was discontinued
in its current form.
Telstra convened two meetings in 1998 to specifically consult with a broad
range of organisations providing services to people who are Deaf, or have a
hearing impairment, on proposed changes to the Disability Equipment
Program (DEP) in order for Telstra to meet its obligations as the Universal
Service Provider under the Telecommunications Act 1997 and
Telecommunications (Equipment for the Disabled) Regulation 1998.
Telstra held the first of its new bi-annual Disability Consumer Forum
consultation meetings in March 1999. Initial feedback from this new-style
consultation forum was very positive and the second meeting was held on 21
September 1999. A summary report of the forum is produced and circulated
to all interested parties in preferred formats. This includes all disability
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members of the Telstra Consumer Consultative Councils (TCCC). An HTML
version is made available for inclusion on consumer web sites.
Throughout 1996–98, meetings of the national and eight regional Telstra
Consumer Consultative Councils were held three times per year. Each of
these Councils has at least one representative from the disability community.
The following disability organisations have been involved with Telstra’s
consultation process at either the national or regional level:
1. ACROD
2. Advocacy Victoria
3. Australian Association of the Deaf
4. Barwon Disability Resource Council
5. Blind Citizens Australia
6. Communication Aid User Society
7. Crippled Children's Assoc of SA Inc
8. Deafness Association NT
9. Deafness Forum
10. Disability Resources Centre (VIC)
11. Disabled Peoples Initiatives (ACT)
12. Disabled Persons International (NT)
13. National Caucus of Disability Consumer Organisations
14. National Ethnic Disability Alliance
15. People with Disabilities (NSW) Inc.
16. People with Disabilities WA Inc
17. Physical Disability Council of Australia
18. Queensland Council of Carers
19. Queensland Disabled Peoples International
20. Tasmanian Council of the Deaf
21. Tasmanians with Disabilities
22. Telecommunications & Disability Consumer Representation Project
23. Victorian Council of the Deaf
24. Victorian Services for Deaf Children Inc
25. VISION Resources NT
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By way of example, 44 disability-related issues were raised in these forums in
1996/97 covering matters relating to the Disability Equipment Program, access
issues (to Telstra Shops, Payphones, Directory Assistance, etc.), affordability
issues, issues or clarification about a range of products and services such as
mobiles, EasyCall features and Call Connect. The issues were sometimes
raised by consumers, and sometimes by Telstra as a means of increasing
community awareness on particular initiatives or developments. The
discussions ranged from short explanations or clarifications through to in-depth
briefings and consultation.
A number of regular communications are sent to all TCCC members. These
include:
(i) Consumer Exchange, the newsletter of the Consumer Councils, published
twice a year, with news about consultation on Telstra’s Disability Services (it
is also distributed to a wide range of other community and government
organisations as well as internally in Telstra);
(ii) Minutes of the TCCC National meeting;
(iii) a report by the TCCC Consumer Secretariat produced biannually, which
includes a consumer perspective on consultation and where relevant Telstra’s
Disability Services; and
(iv) a report of the issues discussed at the regional TCCCs is produced twice
per year. When relevant, this includes material that can be included in
consumer newsletters about Telstra’s Disability Services.
3.2 Periodically update Telstra’s catalogue of DDA resource material.
Telstra has undertaken a range of consultation with the Human Rights and
Equal Opportunity Commission, representatives of other Corporations, and a
range of Government and industry bodies, in additional to seeking periodic
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legal advice on specific matters, to ensure that Telstra has available to it the
most up to date and fully informed information regarding the DDA, how it
might be interpreted and key issues of concern to the disability sector.
A series of workshops were undertaken to brief Product and Project
Managers and Product Developers about the Disability Discrimination Act
1992. In addition, as part of the Product Development process, a series of
Help Files, which supplement the Disability Impact Statement and other
proformas, have been developed.
3.3 Undertake periodic research projects to monitor the needs of people with
a disability in accessing telecommunications.
The Telstra Consumer Consultative Council (TCCC) provided resourcing to
Blind Citizens Australia in 1996 to undertake a project investigating customer
information access for people who are blind or vision impaired. The project
highlighted telecommunications more than banking and government
information issues because the “telecommunications infrastructure and
useability factors” were considered to underpin many aspects of information
access. A number of the recommendations made in the report have since
been implemented, eg. development of Yellow Pages Direct allows people
who are blind or with vision impairment to gain access to Yellow Pages
entries, and the introduction of the availability of the Telstra Bill in Braille.
In 1997, Telstra undertook statistically significant research into the usage of
the Disability Services page in the front of the White Pages Directory. The
results of the survey were utilised to re-format the Telstra information pages
in the White Pages directory, which were cited as being a more important
source of information than the Disability page. The research also identified
the importance of health professionals and service provider organisations in
disseminating information to their relevant client base. This information has
been utilised to ensure effective targeting of information about Telstra’s
products and services for people with disabilities.
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Telstra’s Disability Services Unit undertook a two-stage market research
program to identify the needs of customers with disabilities, involving
qualitative and quantitative research. This program was completed in 1997
and provided information on levels of satisfaction with Telstra’s range of
products and services, as well as levels of awareness of Telstra’s Disability
Services. This research has assisted in the development of Telstra’s
communication program being implemented in 1999 and guided the
development of some new services for people with disabilities.
Telstra’s Research Laboratories (TRL) undertook a study to improve access
to Telstra’s Internet services for customers with a vision impairment. It
focussed on two Internet-based applications that were currently under
development at TRL and resulted in a number of outputs in 1998, including
sets of guidelines and checklists which give Telstra Human Factors
researchers and Web designers a practical guide into making web sites
accessible for people with a vision impairment. The project also provided
input for improvements to the Telstra homepage.
The Telstra Consumer Consultative Council (TCCC) provided resourcing to
the Communications Aid User Society (CAUS) to undertake a research study
into the “Telecommunications Needs of People with Communication/ Speech
Difficulties”. Deakin University completed the study in February 1998.
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Strategy 4: Improve Accessibility to Telstra’s Buildings and Facilities
The aim of this strategy was to provide a mechanism to identify buildings and
facilities which may not be fully accessible to people with disabilities.
PricewaterhouseCoopers review found that 90% of actions had been completed or were in progress for this strategy.
4.1 Review Property Services practices to identify areas for reform.
A building audit process has been developed. Corporate Property Services
has formulated the “National Disability Access Implementation Program”. The
aim of the program is to provide equitable access to all Telstra corporate
owned and leased properties. In order to achieve this, the program has been
developed in two stages:
Stage 1 - Identification of non-compliance items by conducting access audits.
Stage 2 - Rectification of non-compliance items.
An audit of all buildings and facilities was commenced in 1996 with key
strategic buildings being targeted for assessment, and where required,
upgraded initially. Other buildings and facilities will be assessed
progressively over the next five years.
Pre-leasing agreement forms were reviewed. The Works Projects
Management System and Property Management System document all work
procedures. Work processes have also been documented.
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4.2 Development of a Corporate Access Policy
A Telstra Access Advisory Panel (TAAP) was formed by Corporate Property
Services in 1996 to act as an advisory board on matters relating to physical
access to, within and from Telstra’s corporate accommodation buildings, as
well as a wide range of other disability issues.
The purpose of the TAAP is to assist and support Corporate Property
Services in achieving the objectives of the Telstra Disability Action Plan and
ensure compliance with the Disability Discrimination Act 1992 (DDA).
The TAAP meets quarterly and consists of peak representative bodies,
industry technical experts, and advocates representing all areas of disability
and also representatives of Telstra employees with a disability.
4.3 Communicate access policies and practices to relevant staff.
Disability Awareness Training Seminars were delivered to all Corporate
Property Services staff to assist in meeting Telstra’s commitments with
respect to the DDA and the Telstra Disability Action Plan.
Corporate Property Services, with the assistance of the TAAP, has formulated
access policies, guidelines, an access audit checklist and emergency
evacuation procedures for people with disabilities.
4.4 Develop and implement a Works Program (to include targeted completion
dates)
The PwC review found that this action point had not been actioned. Since the
review, works programs have been completed for each State covering priority
one buildings, ie. those buildings which have a high profile/high public usage
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within each State. Audit summaries are continuing for remaining buildings
and works programs are being continuously updated.
However, in relation to the Telstra Retail Shop network, with the assistance of
the TAAP and various access consultants, a “Retail Shop Disability Design
Brief” has been developed. This document has been applied to the new
designs and refurbishment of the Telstra Retail Shop outlets on a national
rollout program. The brief outlines and specifies design requirements to be
followed to accommodate people of all abilities, therefore making the shops
accessible to all members of the public.
The standard retail fitout currently being implemented incorporates a
continuous process of design review by an Access Consultant and the TAAP.
An appointed access consultant reviews all proposed shop design details
(which have been developed in accordance with the design brief) and
provides recommendations in relation to improved access design for people
with disabilities. Upon completion of the retail shop fitouts, the access
consultant conducts a post occupancy evaluation of the shop.
All new retail shop fitouts are incorporating a hearing induction loop at the
main inquiry/service counter to accommodate people with hearing
impairments.
4.5 Establish a process for reviewing any complaints/suggestions regarding
Telstra’s Access Plan and communicate this to staff and customers.
This process has not been documented due to the very low level of
complaints/suggestions that have been received. Any
complaints/suggestions that are received are dealt with immediately, and can
usually be resolved within Corporate Property Services.
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Strategy 5: Improve Accessibility to Information for People with a Disability
The aim of this strategy was to ensure that customers with a disability have
equal access to Telstra general sales and billing information services.
PricewaterhouseCoopers review found that 89% of actions had been completed or were in progress for this strategy.
5.1 Ensure the continuation of equitable access to Telstra’s customer
services.
Telstra’s TTY Enquiry Line provides a parallel service for people who are
Deaf to Telstra’s main sales and general information service 13 2200. Access
to the TTY Enquiry Line was extended to 7 days a week until the time that the
service was relocated with the Disability Enquiry Hotline (DEH) when the DEH
was centralised in November 1997. The service now operates standard
business hours, Monday to Friday, 8am to 5pm. There are no plans to
expand the operating hours of this service.
Due to the relatively low numbers of calls to this service, customer
satisfaction levels for these services cannot be monitored using Telstra’s
standard monitoring surveys. However, the service is monitored by the
National Telemarketing Centre management in line with other services
provided within that centre and Grade of Service (“GOS”) (the percentage of
calls answered within 10 seconds) is consistently around 95%, with GOS for
other services being at around 80-85%.
TTY access to Telstra is published in the Telstra information pages in the
front of the White Pages Directory, in the TTY Directory and in the publication
A Guide to Telstra’s Services for Residential, Business and MobileNet
customers, which is also available on the Internet.
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Telstra’s Aged & Disability Centres have a central TTY number - 1300 366
299. This service can be accessed for the cost of a local call.
Staff at Telstra’s Disability Enquiry Hotline have received TTY training and
now rotate through the group so that they regularly handle TTY calls and are
able to keep their skills up to date.
Information about Telstra’s Disability Services can be accessed via the
Telstra Internet site at www.telstra.com.au.
5.2 Develop information materials in a range of alternative formats.
Telstra developed a brochure Services for people with disabilities, which it
launched in July 1997. The brochure was developed in four community
languages, braille and audio cassette.
The brochure was distributed via a direct mail campaign to local councils,
disability consumer and service provider organisations, key government
departments and agencies, telecommunications industry agencies and other
key stakeholders. As part of the direct mail campaign, organisations were
provided with an order form for multiple copies of the brochure in printed
English or another language or format.
Telstra utilises the services of the Telephone Interpreter Service where an
enquiry is received from a person who has a disability and who does not
speak English. Telstra also has multilingual sales cells and can assist people
who speak Mandarin, Cantonese, Greek, Indonesian, Italian, Korean and
Vietnamese, in their own language. These numbers are published in the
information pages of the White Pages Directory.
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5.3 Consider the provision of key information and promotional material in
alternative formats.
The TTY Directory was developed in braille in 1996 and Telstra had the
intention of ensuring that each year the Directory was also developed in
braille. Two issues have impacted on the subsequent printing of the TTY
Directory in braille:
Telstra’s National Directory Services was sold to Pacific Access in 1997;
and
the change to 8 digit numbering in Sydney and Melbourne delayed the
printing of the Directory until late last year.
The Guide to Using Telstra’s Telephone Services was first developed in
1995.
Captions are provided on all Telstra advertisements, including those where
the on-screen print matches the voice over.
Various areas of Telstra have been involved in projects to assess whether,
and ensure that, Telstra’s website is accessible. This has included
involvement with the Australian representative on the World Wide Web
Consortium (W3C), a major research project undertaken by the Human
Factors Group at the Telstra Research Laboratories, and discussions with
Telstra’s website managers and developers.
It was Telstra’s intention to establish a formal process for reviewing requests
for converting information into alternative formats when required or upon
request. For those projects where information in an alternative format was
clearly required by customers where a product which would impact on
everyone, such as with Calling Number Display, this has been provided. In
addition, Telstra has responded to all reasonable requests from individuals for
information in other than a printed form. These requests have usually been
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made through the Telstra Consumer Councils, Telstra’s Disability Enquiry
Hotline or one of Telstra’s Aged & Disability Centres.
5.4 When completed, review the recommendations of the National Federation
of Blind Citizens of Australia (NFBCA) report “Consumer Information Project”.
There were 18 recommendations made in the NFBCA report that related
specifically to Telstra. Of these, 13 of the recommendations have been
considered or implemented, with a further 2 recommendations currently being
implemented. Two of the recommendations could not be implemented at this
time. A further recommendation is no longer valid because the Telstra
service referred to no longer exists.
Examples of the recommendations that have been implemented are the
provision of exemptions on Telstra Call Connect, the expansion of the Hello
Yellow service, now called Yellow Pages Direct, and the provision of the
Telstra Bill in Braille.
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Strategy 6: Improve Accessibility to Telstra’s New Products and Services
This strategy aimed to ensure that a formal process was established whereby
any new products under development were assessed for potential
accessibility to persons with a disability, and that customers with a disability
be included in the useability testing of products where possible.
PricewaterhouseCoopers review found that 75% of actions had been completed for this strategy.
6.1 Ensure all new products and services are assessed for potential
accessibility to persons with a disability.
All product managers and product developers are now required to submit a
Disability Impact Statement which is completed at the concept stage of the
Product Development process.
The vast majority of projects assessed were for network modifications or were
targeted at large businesses without any end impact on consumers. Of the
279 products assessed from 7 May 1996 to 31 December 1998, 17 were
found to have a potential impact on accessibility by people with a disability.
Where a product is identified as having a potential impact, the Product
Manager is required to conduct further testing or analysis as advised by the
Disability Services Unit. The product development of that product is then
tracked, and where appropriate consultation with relevant sections of the
disability sector are conducted
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6.2 Include people with a disability, wherever possible, in the useability testing
for new products.
PwC has recorded this particular action point as “Not Actioned”. People with
disabilities are not always specifically included when performing product
testing. A list of participants is usually obtained from an independent
consulting agency that generally does not specifically target people with
disabilities.
However, where a product is identified as having an impact on a particular
sector of the disability community, Telstra seeks the guidance and assistance
of representatives of that sector through its consumer consultation processes.
Examples of specific outcomes that have been achieved through consumer
consultation are the exemptions on Telstra Call Connect, and the provision of
the Telstra Bill in Braille. Consumer representatives on Telstra’s Disability
Services Consultative Committee, assisted Telstra in the development of its
policy and application form for the exemptions on Telstra Call Connect. In
addition, representatives from National Federation of Blind Citizens Australia
assisted and advised Telstra in its development of the Telstra Bill in Braille.
Consumer representatives have, through the consumer consultation process,
urged Telstra to use people with disabilities when developing or testing
products and services. This is done wherever possible.
6.3 Explore the opportunity for people with a disability to take part in the trial
of equipment as part of the Personal Communication System (PCS) trial.
The Secretariat of the Telstra Consumer Consultative Council attempted to
gain the participation of people with disabilities through a disability consumer
representative on the TCCC Victoria. However, despite a number of
invitations, the invitation was not taken up.
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Strategy 7:Improve Accessibility to Telstra’s Existing Products and Services
This strategy was aimed at improving accessibility to Telstra’s existing
products and services. The strategy specifically addressed six products and
services. These are discussed below.
Customer Premises Equipment
The main aim of this section was to establish the Telstra TTY Program and to
ensure that Telstra staff and its customers were informed about the Program.
In addition, Telstra aimed to review the pricing principles that apply to CPE
provision.
PricewaterhouseCoopers review found that 100% of actions had been completed or were in progress for this strategy.
7.1 Establish a TTY Voucher Scheme to provide TTYs or modems to the
profoundly deaf and speech-impaired who are not eligible under the
Government TEA Program.
The Telstra TTY Program was established by Telstra and commenced
operation on March 1 1996. The program was administered by Australian
Communication Exchange and supplemented Telstra’s voluntary equipment
provision program, the Disability Equipment Program (formerly the Disability
Tariff Concession Policy) administered by Telstra.
A media release announcing the launch of Telstra’s TTY Program was issued
to national print and electronic media and to specialist press and disability
consumer organisations. As a consequence, a series of interviews were
conducted on metropolitan and regional radio. A direct mailout to disability
consumer and service organisations Australia wide was conducted at the time
of launch.
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Significant staff communication was undertaken prior to, and after, the launch
of the Telstra TTY Program, with a range of staff briefing materials being
disseminated, supplemented by staff briefings, and placement of articles in all
Telstra’s major internal publications and dissemination via Corporate e-mail.
With the introduction of the Telecommunications Act 1997, the universal
service obligation has been expanded to include the obligation to supply
customer equipment upon request to a person with a disability to enable them
to access the standard telephone service supplied by Telstra.
Telstra’s Disability Equipment Program has now been expanded to include
the provision of equipment formerly made available under the Telstra TTY
Program and the National Relay Service - Telecommunications Equipment
Access (“NRS-TEA”) Program. The expanded program commenced
operation on 17 September 1998.
Three models of TTYs and two models of modems are currently available
under this integrated program. Eligible customers can rent the equipment
from Telstra at a (current) annual hire charge of $30, the same charge as for
the standard rental telephone handset. The equipment remains the property
of Telstra. If the equipment becomes faulty, Telstra will maintain the
equipment at no additional charge to the customer, providing the fault is due
to reasonable wear and tear.
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7.2 Review the pricing principles applied to products and services provided
to people with a disability, including those products provided by the Disability
Tariff Concession Policy.
All equipment provided through Telstra’s Disability Equipment Program (DEP)
is provided at the same rental charge as the standard rental telephone
handset, ie. currently $30 per annum, irrespective of the cost of that
equipment
Telstra, through its breadth of products and services, aims to provide a range
of product and pricing options to its customers. Where a commercial product
provides basic access to the standard telephone service for a person with a
disability who would not otherwise be able to access that service, Telstra has
through its consumer consultation process, developed equitable pricing
policies for those products or developed specialised services where required.
Payphone Services
This strategy focused on improving accessibility to Payphones along with
increasing awareness of the needs of people with a disability. A review of
internal procedures and policies for processing requests for modified
Payphones was also to be conducted.
PricewaterhouseCoopers review found that 100% of actions had been completed or were in progress for this strategy.
7.3-7.7 A range of actions were documented to ensure the development of a
Payphones Access Policy in consultation with disability and community
groups, to implement those procedures and to plan for the alteration of
existing facilities, and to review the Policy.
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The Payphone Access Policy, first issued in 1993, was revised in consultation
with disability and consumer groups during the term of the Plan. The policy
was used as a guide to the sorts of features required in the new Telstra Smart
Payphone. Telstra is currently replacing most of its existing payphones with
the new model payphone and is expected to complete rollout on a national
basis by the end of 1999. The new payphone has an in-built hearing aid
coupling device, volume control feature and is generally accessible by
wheelchair. It is both coin and card operated and takes all Australian coins.
Payphone issues relating to siting and accessibility have been raised in
Telstra’s consultative forums. Telstra management has attended these
forums to respond to the issues raised. Some issues have related specifically
to the availability and siting of TTY payphones, and the development of a TTY
Payphone siting survey was proposed by consumer representatives. This
proposal has been implemented and consultation on the findings will be an
action to be included in the new Plan.
Operator Assisted Services
The action points relating to Operator Assisted Services (now called Telstra
Information and Connection Services - TICS) focussed on TTY access to
emergency services and general access to Operator Services for people with
disabilities.
PricewaterhouseCoopers review found that 100% of actions had been completed or were in progress for this strategy.
7.8 Ensure TTY accessibility to emergency 000 services.
Agreement was reached in January 1996 between Australian Communication
Exchange and Telstra for TTY access to the emergency service number 000
via the National Relay Service through FREECALL 1800 067 167.
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Telstra’s operators answer some nine million calls to 000 each year. Of
these, only a small proportion (30%) are genuine emergency calls, with the
vast proportion being hoax or misdialled calls to fax machines or overseas
numbers. There are approximately 120 operators who are trained to handle
calls to 000.
In order for a call from a TTY to 000 to be answered by a Telstra operator,
the operator would have to first distinguish the TTY tone from a fax or modem
call, and then be sufficiently skilled in the use of a TTY, Deaf culture and TTY
etiquette to handle the call appropriately. This option was seen as posing a
greater risk to the customer than having those calls answered by a Relay
Officer at the National Relay Service who was skilled in the use of a TTY.
Telstra worked with the various Deaf organisations and the National Relay
Service to promote the establishment of the TTY Emergency Call number.
The number is promoted in the inside front covers of the White Pages
Directory and the TTY Directory.
A separate three-digit emergency number has now been established by the
Australian Communications Authority and is presently being tested for
implementation. This emergency number is expected to give faster access to
emergency services for people with disabilities. Access to this number will be
operational from 1 March 2000 when the new Telecommunications
(Emergency Call Person) Determination 1999 (“ECP Determination”) comes
into operation. Under the ECP Determination, the NRS Provider (which is
currently Australian Communications Exchange Ltd) is specified to be the
national operator of emergency call services for calls made to the emergency
service number 100.
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7.9 Investigate any difficulties in accessing Telstra’s Operator Assisted
Services, in consultation with the community.
Telstra has operated a Directory Assistance Disability Helpline (DADH) since
1988 for people who need more time and assistance with Directory
Assistance (013). In 1996 the policy was revised in consultation with
consumer groups to ensure the service met the needs of consumers who
could not read, hold or use the White Pages directory and are unable to
satisfactorily use the 013 service. The Helpline currently has over 1000
registered customers.
Some difficulties and complaints were reported by people who were not able
to access address information through Directory Assistance. As a result, a
revised learning brief was developed and distributed to OAS staff in late
1998.
Directory Services
The aim of this strategy was to improve Directory Services for TTY users,
along with other services provided for people with a communications
impairment.
PricewaterhouseCoopers review found that 100% of actions had been completed or were in progress for this strategy.
7.10 Establish a process to upgrade and improve the accuracy of the TTY
directory
A TTY Directory - User Survey is scheduled for distribution at the time of
delivery of the new issue directory in 1999.
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In order to improve the level of service to clients of the Telephone Typewriter
Directory, Pacific Access is currently drafting the Product Plan and Rates
Proposal. This document covers development and product improvements
and will be incorporated into the 1999-2002 Product Plan.
Pacific Access provides TTY access to its product support area. Staff are
trained in the use of a TTY.
The Directory Assistance Disability Helpline, established in 1988, continues to
provide assistance to people with a speech or communications impairment.
In addition, a range of Directory products, including the White Pages on the
Internet, has been developed to provide alternative access to Directory
information.
Mobile Communication Services
This strategy involved monitoring and consultation in relation to issues faced
by hearing aid users and people with a disability when using mobile phones.
PricewaterhouseCoopers review found that 100% of actions had been completed for this strategy.
7.11 Monitor technological developments for TTY/text interface equipment
to identify opportunities for making TTYs more accessible to mobile
communication products.
The incompatibility of TTYs and mobile technology remained an outstanding
issue for the term of the Plan, and although the issue was investigated and
discussed, there appeared to be no immediate solution. It seems that there
are now overseas examples of mobile textphones. This breakthrough will be
identified as an action for further investigation under Telstra’s new Disability
Action Plan.
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7.12 Continue to consult with industry bodies, disability groups, AUSTEL
(now Australian Communications Authority) and the government to resolve
the issue of GSM interference to hearing aids.
There has been a considerable focus on the government’s decision to close
the analogue network in major metropolitan areas and some country areas on
31 December 1999, with total phase out in the remaining rural areas by 31
December 2000. People with hearing aids are concerned that digital mobile
phones may cause interference with their hearing aids.
Telstra’s CDMA network is planned to enter service during the latter part of
1999 and when completed in 2000 will provide reasonably equivalent
coverage to Telstra’s AMPS and GSM networks.
Telstra has commissioned independent testing through Australian Hearing.
This testing is showing preliminary results that are encouraging. A clearer
indication will be available after the testing has been completed. This issue
remains one for further action under the new Plan.
Other Products and Services
This strategy aimed to improve the accessibility of products and services
provided by Telstra, its subsidiaries and its commercial partners as a result of
customer feedback through a range of communications channels.
PricewaterhouseCoopers review found that 33% of actions had been completed.
7.13 Review other existing products and services, on an ongoing basis.
Issues in relation to products and services raised in Telstra’s consultative
forums, customer complaints recorded in accordance with Telstra’s complaint
management process, complaints to the HREOC, the Telecommunications
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Industry Ombudsman (“TIO”), the Australian Communications Authority
(“ACA”) and Ministerials, information received through journals and other
publications, and information received from Product Managers through the
Product Development process, are all taken into account and form the basis
of decision making.
7.14 Ensure Telstra’s Disability Policy is also adopted by Telstra’s
subsidiaries.
The adoption of Telstra’s Corporate Policy - Disability by its subsidiaries and
joint venture partners is to be considered over the next six months. The policy
is available on the Telstra Intranet site, to which all Australian subsidiaries
have access.
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Strategy 8:Maintain Telstra’s Commitment to the Elimination of Discrimination in the Workplace in Accordance with Telstra’s EEO Policy.
Areas such as compliance with Telstra’s employment policies and increasing
employment opportunities for people with a disability were addressed in this
strategy.
PricewaterhouseCoopers review found that 100% of the actions in this strategy were completed.
8.1 Review Telstra’s employment policies and practices to ensure all are
non-discriminatory.
Telstra’s Senior EEO Consultant, Disability is part of the Employment team
within Employee Relations. It is this team which is responsible for the design
and development of Telstra’s employment policies and practices. Maintaining
a profile in this area of the organisation has ensured disability issues are
considered when changes are made to policies or procedures or where new
processes are being developed.
In addition to disability being included in all statements pertaining to Telstra’s
Fair Treatment process, Equal Employment Opportunity and Recruitment, a
separate statement specifically for disability discrimination has been
designed. All Telstra staff can access this information via Telstra’s Intranet.
Documents including training notes, information relating to Telstra shares and
Telstra staff share offers, brochures, Telstra’s Code of Conduct and articles
from Our Future have been made available in braille to Telstra staff who are
blind. Documentation has also been made available in large print for staff
requiring this format.
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Deaf staff have been provided with Auslan interpreters for team briefs.
Information on subjects including health and safety, employment information,
Telstra’s Fair Treatment process and policies such as EEO are provided to
staff in these meetings. Interpreters have also been utilised at information
sessions conducted in order to provide Telstra staff with information about
staff share offers.
The Telstra Intranet is accessible to all staff. Information provided includes
policies and procedures relating to all aspects of employment. The Intranet
has been beneficial in that it has provided more flexible access for staff with
sensory disabilities. The information can be captured and presented in a
variety of formats. A person with a vision impairment can access the
information using voice adaptive technology to have the information read
aloud via computer, or use a zoom facility to enlarge the size of the text.
8.2 Facilitate further employment of people with a disability within Telstra.
Telstra’s Disability Employment Program continues to be successful in
providing employment opportunities for people with a disability.
Telstra’s recruitment and selection policies and procedures support the
commitment Telstra has to the employment of people with a disability.
Telstra’s recruitment policies and procedures stipulate that people with a
disability and Aboriginal & Islander applicants need only to be considered
competent to do the work to be selected, as opposed to the best person
based on merit. Further for external recruitment, all vacancies are to be
referred to the Senior EEO Consultant, Disability. This inclusion provides a
greater opportunity for people with a disability to have access to information
about the job.
Telstra’s preferred suppliers have been provided with information relating to
Telstra’s EEO commitments and in many instances have been provided with
information sessions on Telstra’s Disability Employment Program. Many of
Telstra’s preferred suppliers have accessed training to enhance their ability to
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meet Telstra’s targets in the area of recruitment of people with a disability.
This training has been provided by a number of agencies including Central
Marketing Services, an organisation funded by the Employer Incentives
program within the Department of Family and Community Services and the
Commonwealth Rehabilitation Service.
Increasingly employment in Telstra includes temporary and casual jobs. As
these opportunities have increased Telstra has undertaken work with
preferred suppliers and disability specific agencies to increase opportunities
for people with a disability in temporary and casual job markets within Telstra.
This work has resulted in an increase in representation of people with a
disability gaining employment within Telstra.
Telstra offers EEO Scholarships to students who are members of the EEO
target groups. People with a disability have been amongst those awarded
these scholarships in the last 2 years. The scholarships include a monetary
component and employment.
Telstra established its Paralympic Employment Program (PEP) in June 1997.
Through this program, Telstra aims to employ up to 10 Paralympic level
athletes by the Year 2000. Candidates are chosen on merit and where a
suitable job opportunity exists. To date six athletes have been employed
under this program.
People with a disability have also been employed through Telstra’s Graduate
Program.
Telstra continues to make reasonable adjustments to the physical
environments in which people with a disability work, and the job roles where
necessary and as appropriate.
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Strategy 9:Incorporate DDA Requirements into Existing Telstra Policies and Programs.
This strategy aimed to ensure that customer information remain confidential,
that Telstra’s policies be non-discriminatory and ensure its pricing of products
and services provided to people with a disability are reviewed.
PricewaterhouseCoopers review indicated that 100% of actions outlined under this strategy have been completed.
9.1 Ensure any information collected to verify a customer’s disability
remains confidential in strict adherence with Telstra’s Privacy Policy.
Telstra is committed to the protection of personal privacy. To meet this
commitment, Telstra has adopted a set of principles, policies and procedures
to protect the privacy of its customers. These were developed in consultation
with the Telecommunications Industry Ombudsman and the Privacy
Commissioner, and include:
The proper use and protection of customer personal information and
information gathered in the course of service provision by Telstra;
The need to actively consider privacy issues as new products and
services are developed.
Telstra maintains an independent compliance audit program to ensure its
Privacy Protection Principles and policies remain appropriate and that it
operates in compliance with those principles and policies. A Privacy Audit
Panel monitors the independent program. A yearly report on the audits
conducted under the auspices of the Privacy Audit Panel, and their outcomes,
is available to the public.
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The consideration of privacy issues in the development of new products and
services is executed through Telstra product development process which
ensures impacts in relation to privacy are identified and conform with Telstra’s
privacy policy.
9.2 Review other policies as and when the need arises to ensure they are
non-discriminatory.
Policies have been reviewed in light of Telstra’s Disability Action Plan with
adjustments being made to Telstra’s product and service offerings.
9.3 Review the pricing principles applied to products and services provided
to people with a disability as required.
The principal example of a pricing review affecting products and services
provided to people with a disability is the development of the annual rental
charge of disability equipment under the Disability Equipment Program which
is the equivalent to the rental charge of a standard telephone handset.
One outstanding issue that has been strongly represented by the Deaf and
speech-impaired community has been the cost of long-distance calls for TTY
users. The issue stems from the longer time it takes to communicate with a
TTY. The difficulty for Telstra is that the network cannot distinguish between
a TTY and voice call. However, we note that the real cost of long distance
calls has dropped dramatically in recent years.
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5.2.1 Consumer Feedback
As mentioned earlier, not all organisations that were invited to provide
feedback did so, and feedback was not received on each action. The
following section provides an overview of the qualitative assessment by some
of the nine members of Telstra’s Disability Consumer Forum, and is based on
the individual’s knowledge of Telstra’s activity in a particular area.
Consumer representatives provided feedback on the implementation of
Telstra’s Disability Action Plan on four strategies, these being:
Strategy 3: Ensure ongoing community consultation
Strategy 4: Improve accessibility to buildings and facilities
Strategy 5: Improve accessibility to information
Strategy 7: Improve accessibility to existing products and services,
including CPE, Payphones, OAS, Directory Services, Mobiles, and
other products and services
Generally consumers responded that they were ‘partly satisfied’ in the
majority of cases where a response was given. However, the variety of
responses to some actions was quite mixed with responses ranging from
‘satisfied’ to ‘ not satisfied’. This disparity in feedback seems to reflect sector
specific differences in needs and highlights the very real difficulty of providing
products and services that are accessible to all people with a disability.
Consumer organisations indicated the highest level of satisfaction with
Telstra’s consultation process and the research projects it had undertaken
(strategies 3.1 and 3.3). Consumers comments reflect that they still feel that
consultation is too infrequent, but acknowledged that this has increased over
the past few years. Consumers’ views differed on whether the research that
Telstra has conducted is sufficient, with some consumers stating that they
would like to see Telstra being more proactive in initiating research projects
generally, but specifically developing unique customer equipment not made
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elsewhere in the world. Where research projects have been undertaken,
consumer feedback indicated an expectation that all recommendations of any
report could, and would, be implemented. Research is used as a guide in
Telstra’s planning process, and some recommendations will at times not be
implemented, because of technical limitations or for commercial reasons.
Consumers expressed a level of satisfaction, but not without some
reservations, with the provision of information in alternative formats
(strategies 5.2 and 5.3), the establishment of the TTY Voucher Program
(strategy 7.1), the review of the Payphones Access Policy (strategy 7.4), the
upgrade of the TTY Directory (strategy 7.10) and Telstra’s consultation with
industry bodies etc, on the issue of GSM interference and hearing aids
(strategy 7.12).
The issue of greatest concern to consumers was TTY access to emergency
services. Consumers felt that the current arrangement of contacting
Emergency Services by calling via the National Relay Service on
FREECALL1800 067 167, was seen to be an unacceptable compromise.
As indicated in the discussion of strategy 7.8, a new three-digit number has
been established and will be operational by early next year.
Other areas of concern raised by consumers were with strategies 7.8 and 7.9
- access to Operator Assisted Services (now called Telstra Information and
Connection Services), and the provision of public payphones (strategies 7.3-
7.7), with consumers indicating that these services were not fully accessible
by all persons with a disability.
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6. HREOC Complaints
During the life of Telstra’s Disability Action Plan there have been 5 disability
discrimination complaints referred to Telstra by the Human Rights and Equal
Opportunity Commission. Telstra was notified of one complaint late in 1997
and a further four complaints during 1998. Two of these complaints have
been closed.
The broad nature of the complaints are as follows:
Access to Telstra’s new public payphones - complaints;
Bill payment methods and access to address information via Directory
Assistance;
Access to address information via Directory Assistance; and
Access to mobile services for a customer with a hearing aid upon closure
of the AMPS (Advanced Mobile Phone System) Network.
The process for receiving and responding to a complaint is that the Disability
Discrimination Commissioner writes to Telstra’s Chief Executive Officer to
notify him of the complaint. Telstra has 21 days in which to respond.
Telstra’s Disability Services Unit is usually notified of the complaint by the
Chief Executive Officer’s Office and oversees the dissemination of the
correspondence to the relevant Business Unit/s or business area/s within the
Corporation and, where appropriate, will coordinate Telstra’s response to the
Commission and participate in any conciliation conferences.
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7. Future Direction
As outlined above, Telstra has completed approximately 65%, and has
another 26% in progress, of the actions outlined in its nine strategies in its
first Disability Action Plan. We feel that this is a positive result when
considering:
the size of the Corporation and the breadth of its product and service
offerings;
the significant change within the telecommunications industry since the
Plan was first submitted; and
Telstra was the first corporation to prepare and submit a Disability Action
Plan to the Human Rights and Equal Opportunity Commission.
Telstra acknowledges that there are areas where it can improve access to its
products and services. We are currently in the process of preparing our next
three-year Disability Action Plan and this will incorporate key areas identified
as requiring improvement. The next Disability Action Plan will also
incorporate those actions/activities that are currently “in progress” or “not
actioned” from our first Plan where appropriate.
As detailed in our initial Plan, consideration is being given as to how best
mainstream the Disability Action Plan initiatives into Telstra’s normal business
planning within each of the business units. Our aim is to ensure that the
initiatives are addressed on a regular basis by the business units thus
improving the services and products offered to people with a disability.
In addition to the Disability Action Plan, Telstra’s Disability Services Unit
undertakes a range of activity to ensure that access to Telstra’s services, and
that an awareness of the needs of people with a disability, are maintained.
For example:
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Telstra has sponsored LINK magazine for 5 years. The magazine’s
subscribers are primarily people with a disability, community and service
provider organisations and health professionals.
Through targeted sponsorships Telstra seeks to positively promote the
abilities and aspirations of people with a disability.
The reformatting of the Telstra pages in the White Pages telephone
directory in 1998/99 provided an opportunity to more prominently include
the contact numbers of services for people with disabilities. The
FREECALL numbers for the Disability Enquiry Hotline and the TTY Enquiry
Line now feature on page 2 of the White Pages, directly under the principal
contact numbers for sales, billing and product information.
The Guide to Telstra’s Services for Residential Business and MobileNet
Customers, also published on Telstra’s Internet site, includes a section on
Telstra’s Disability Services. The Guide, now in its third edition, was
initially launched in 1995.
The Disability Enquiry Hotline (DEH) is the primary contact point for
customers wishing to enquire about or apply for equipment under the
Disability Equipment Program.
The six Aged and Disability Centres have been maintained and continue to
provide a contact point for people with disabilities.
Telstra is proud of the progress it has made to date, and remains committed
to ongoing improvement in access to its products and services, building
facilities, and employment opportunities for people with a disability.
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APPENDIX 1:
Letter from PricewaterhouseCoopersDated 12 November 1999